Italy Legge 8 agosto 2024 n. 115 (conversion of DL 84/2024) — Disposizioni urgenti sulle materie prime critiche di interesse strategico

Mechanism

Decreto-Legge 25 giugno 2024 n. 84 was approved by the Italian Council of Ministers on 25 June 2024 and entered into force the same day pending parliamentary conversion. The conversion law (Legge 8 agosto 2024 n. 115) was approved definitively by the Senate and published in the Gazzetta Ufficiale on 13 August 2024, entering into force on 14 August 2024 with amendments to the original DL text. Italy is one of the first EU member states to enact a standalone national CRM statute specifically implementing Regulation (EU) 2024/1252.

Four operative pillars

1. National Governance Framework (Articles 1–4) MIMIT is designated as the central coordinating authority for Italy's strategic-CRM policy. A permanent Technical Committee for Critical and Strategic Raw Materials is established at MIMIT (Article 6) to monitor supply-chain dynamics, conduct stress tests, and coordinate with EU-level governance structures under the CRMA's European Critical Raw Materials Board (ECRMB). MASE has parallel competence for environmental-authorisation aspects of extraction and recycling.

2. National Register of Strategic Companies and Value Chains (Articles 5–7) Large enterprises operating in Italy that use strategic raw materials in high-priority sectors (batteries, aircraft, mobile electronics, robotics, renewable energy equipment, semiconductors) must register with MIMIT. The register enables supply-chain mapping, annual import/export reporting on strategic-material flows, and demand-side stress-testing against supply disruption scenarios. MIMIT was required to identify qualifying sectors by decree no later than 24 May 2025.

3. Divided-Competence Permitting (Article 8) A single-window streamlined authorisation procedure with statutory deadlines aligned to CRMA Article 11 strategic-project timelines:

• Extraction projects: MASE authority, max 18-month permitting clock
• Recycling projects: MASE authority, max 10-month permitting clock
• Transformation projects: MIMIT authority, max 10-month permitting clock

4. Strategic-Projects Designation and Financing (Articles 9–11) Italy's national gateway for projects seeking EU Strategic Project designation under CRMA Article 6 (covering the 17 CRMA strategic raw materials — Li, Co, Ni, graphite, Nd, Dy, Cu, Mn, Mg, Ga, Ge, Bi, B, Ti, Si, P, and Sb). INVITALIA and CDP serve as mandated co-financing windows under dedicated facilities. Projects receiving national strategic designation are fast-tracked through the MASE/MIMIT permitting regime.

Italian industrial footprint

Italy is a mid-tier EU industrial economy with material exposure to strategic-CRM supply chains:

• Steel: Acciaierie d'Italia (ex-Ilva, Taranto) — one of Europe's largest steel plants,

dependent on manganese, cobalt, and scrap-metal supply chains

• Aluminium: historic Portovesme + Eurallumina cluster (Sardinia), bauxite/alumina processing
• Copper: Aurubis Italia refining operations
• Zinc/Lead: Glencore Portovesme smelter (Sardinia) — Europe's largest zinc smelter
• Lithium: Sardinian geothermal brine pilots (Vulcan Energy, Energy Source)
• REE/Critical minerals exploration: Tuscany + Sicily geological surveys (INGV + Eni)

Italy's northern manufacturing belt (automotive components, aerospace, robotics, machine tools) creates significant downstream demand for processed CRMs — particularly cobalt (EV battery cathodes), neodymium (permanent magnets for motors and wind turbines), and silicon (solar/semis).

EU CRMA alignment

This filing is the national-implementation counterpart to the EU parent:

• Parent regulation: 2024-05-23-eu-crma-entry-into-force (Regulation (EU) 2024/1252)
• EU strategic projects first designation: 2025-03-25-eu-crma-strategic-projects-first-designation

— 47 EU + 13 third-country projects; at least 6 Italian projects were included in the first designation round, covering lithium, copper, and REE extraction/processing

Structurally peer to: French Loi Industrie Verte CRMA-implementation provisions (transposition via ordonnances), German BMWK Nationaler Rohstoffsicherheitspakt, Spain PERTE CRM (pending formal filing), and Sweden Minerals Strategy 2025.

Downstream implications

• Establishes Italy's legal conduit for projects to qualify for EU Strategic Project status

and the associated CRMA-mandated permitting acceleration (18 months for extraction, 12 months for processing — stricter EU ceiling vs. Italy's own 18/10/10 month regime)

• National Register creates systematic visibility into Italy's strategic-material import

dependencies — the first compulsory supply-chain mapping obligation for Italian industry

• INVITALIA/CDP financing facilitation windows could materially de-risk early-stage

lithium/REE exploration in Sardinia, where geological potential is partially validated

• Divided MASE/MIMIT competence risks inter-ministerial coordination friction for

projects that span extraction + transformation stages (integrated mining-to-processing)

• Italy's Taranto steel hub (Acciaierie d'Italia restructuring ongoing) is a potential

early beneficiary of state-aid windows under the strategic-projects financing regime

Open questions

• MIMIT sector-designation decree (due by 24 May 2025): which sectors formally trigger

National Register obligations — and whether Italian automotive OEMs / Tier-1 suppliers (Stellantis, Ferrari, Leonardo, Thales Alenia Space) are captured

• CDP financing terms for strategic-CRM projects: whether sovereign risk-sharing instruments

(guarantees vs. equity co-investment) are available, and whether EU CRMA Art. 22 financial support provisions interact with Italy's PNRR budget envelope

• Implementing decrees specifying the royalty/fiscal incentive architecture for Italian

mining concessions under the new strategic-projects regime — key gap vs. peer EU statutes